QLTS Solutions and Bloombury Professional Group, its group of companies, subsidiaries and affiliates (collectively, the “Company”) is an enterprise carrying out the business of providing professional education and consultancy services. This is the privacy notice (“Notice”) of the Company (hereinafter referred to as “we”, “us”, or “our”).
The Data Protection Act 1998 (the “Act”) gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a processing fee of £15 to meet our costs in providing you with details of the information we hold about you.
We view your Personal Data seriously and we are committed to protect your Personal Data which we receive about you. This Notice sets out the basis of how we fulfil this commitment to you in relation to the collection, processing, handling and the disclosure of your Personal Data which we obtain or shall obtain in relation to your access and use of our products and services on our website at all times.
By providing and disclosing your Personal Data to us and continuing to use our services and products offered on our website, you hereby irrevocably declare that you have read and understood the terms and conditions of this Notice and you give us your consent to process and use your Personal Data in accordance with the manner set out under this Notice.
If you do not agree to this Notice or any amendments to this Notice, we may not be able to render any services to you and you may be required to terminate your relevant agreement with us and/or stop accessing or using our website.
1.1 In this Notice, the following terms carry the following meanings:
1.1.1“Data” means any information that is being processed by means of equipment operating automatically in response to instructions given for that purpose, is recorded with the intention that it should be processed by means of such equipment, or is recorded as part of a relevant filing system or with the intention that it should form part of a relevant filing system.
1.1.2 “Personal Data” means any information in our possession or control that relate to a living individual who can be identified from those data, or from those data and other information which is in the possession of, or is likely to come into the possession of, the data controller, and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.
1.1.3 We may “process” and “use” your personal data by way of a variety of methods including but not limited to collecting, recording, storing, holding, and/or disclosing it.
1.1.4 The Personal Data which we collect and process about you may include but is not limited to:
a) Name, date of birth, address of residence;
b) Marital status and occupation details;
c) Employer name, income range, job title and job responsibilities;
d) Identity card number or passport number;
f) Education and race;
g) Contact information such as telephone numbers and e-mail addresses;
h) Your financial information;
i) Information about your transactions with us;
j) All other personally identifiable information that you may provide to us from time to time; and
k) Any additional information that is provided by you or third parties about you.
1.1.5 a “person” includes a reference to any individual, firm, company, corporation or other body corporate, government, state or agency of a state or any joint venture, association or partnership, works council or employee representative body (whether or not having a separate legal personality).
1.1.6 a clause or schedule, unless the context otherwise requires, is a reference to a clause of, or a schedule to, this Notice;
1.1.7 a paragraph, unless the context otherwise requires, is a reference to a paragraph of a schedule to this Notice; and
1.1.8 unless the context otherwise requires, the singular shall include the plural, and vice versa;
2. COLLECTION OF PERSONAL DATA
2.1 We may collect Personal Data from you during your course of dealings with us in any way or manner including pursuant to any online transactions and/or communications made from/with us through our website. Your access of our website may be recorded for analysis on the number of users to the website and general usage patterns.
2.3 It is also the case that data are collected from users and other sources in the ordinary course of the online services and transactions carried out on our website. Without being exhaustive, the following are examples of how we can collect your personal data:
a) When you register and disclose to us your personal details on our website;
b) When you complete purchase orders, requests or applications for our products or services online on our website;
c) When you participate in any online surveys or types of research;
d) When you subscribe to our mailing list; and
e) When you communicate with us directly via our customer sales representative.
3. USE AND PROCESSING OF YOUR PERSONAL DATA
3.1 We may process and use your Personal Data for the following purposes, which include but are not limited to:
a) provide you with information, products or services that you request from us or which we feel may interest you;
b) considering the processing of applications, services and/or facilities provided to customers;
c) notify you about changes or updates to our products and services;
d) carry out our obligations arising from any contracts entered into between you and us;
e) ensuring compliance with the relevant laws;
f) for fraud or crime prevention, audit and in order that services and online bookings may be processed by us;
g) for investigating, reporting, preventing or otherwise in relation to breach of any relevant laws, fraud, money laundering, terrorist financing and criminal activities generally;
h) sending you important information regarding our website, our online offers and promotions, changes to our terms, conditions, and policies and/or other administrative information;
i) allowing you to send messages regarding our website-related content to a friend through our website. If you wish to use this feature, you may be required to provide us, and we may use, your friend’s email address;
j) for our internal business purposes, such as data analysis, audits, developing our new financial services products, enhancing our website, improving our services, identifying usage trends and determining the effectiveness of our promotional campaigns;
k) establishing your identity and background;
l) maintaining and improving customer relationship;
m) assessing, processing and providing financial services and/or facilities to you;
n) responding to your enquiries or complaints and resolving any issues and disputes which may arise in connection with any dealings with us;
o) direct marketing purposes via the internet, SMS messages, phone calls, emails, fax messages, mails and social media;
4. DISCLOSURE OF YOUR PERSONAL DATA
4.1 In general, data held by us relating to an individual will be kept confidential but we may provide or disclose your personal data to the following parties:
a) Third party companies or persons;
b) Any other person who holds and is bound by a duty of confidentiality to us which/who has undertaken to keep such information confidential;
c) Our group company, subsidiary, entity or affiliate;
d) Any third party financial institutions, insurers/takaful operators, money changers, credit card companies, securities and investment services providers;
e) Government bodies, relevant authorities and regulatory bodies;
f) Persons authorised by you;
g) any other person or entity as required by any law, regulation, court order or arbitration decision, as the case may be;
h) to our third party service providers who provide services such as website hosting, data analysis, payment processing, order fulfilment, infrastructure provision, IT services, customer service, e-mail delivery services, credit card processing and other similar services to enable them to provide services;
i) to third parties to enable your online orders and purchases to be processed and transacted, including to our moneychanger partners to enable them to fulfill your order;
j) to persons or entities for the purposes identifying you to any person to whom you send messages regarding website-related content through the website;
k) to an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
l) to persons or entities as we believe to be appropriate:
i.under applicable law including laws outside your country of residence;
ii.to comply with legal process;
iii.to respond to requests from public and government authorities including public and government authorities outside your country of residence;
iv.to enforce our terms and conditions;
v.to protect our operations or those of any of our affiliates;
vi.to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and
vii.to permit us to pursue available remedies or limit the damages that we may sustain.
4.2 Your personal data may also be shared or transferred to any location around the world and may be stored in any server or domain located anywhere around the world for any of the purposes set out in this Notice.
5. ACCURACY OF YOUR PERSONAL DATA
5.1 We are not responsible and do not make any warranty or representation as to the completeness or accuracy of the Personal Data that we obtain from users or customers. In no circumstances, can we be held liable for damage or loss of any kind that may arise as a result of actions performed by any person or entity while using or relying on the data, products or services that they offer. Anyone intending to make use of products and services must read and follow all instructions accompanying the product or service and must comply with all applicable laws, rules and regulations for the use of the product or service.
5.2 We endeavor to keep all Personal Data accurate, complete, up-to-date and reliable insofar as we can. To allow us to do so, you warrant and declare that all your Personal Data submitted to us are accurate, not misleading, updated and complete in all respects for the purposes of using of using our online products and/or services. You also undertake to promptly update us as and when such Personal Data provided earlier to us changes in any respect by contacting us at the contact details below.
6. ACCESS AND AMENDMENTS
6.1 We reserve the right to revise, amend, alter and vary this Notice from time to time without giving you any prior notice and you shall be deemed to have agreed to such revision(s) if you continue your relationship with us and accessing our online services on our website. As such, you are advised to check this Notice on a regular basis from time to time. The latest amended version of the Notice shall supersede the previous version of the Notice so amended.
6.2 As provided for under the relevant data protection laws, you have the right to request access and correction to the Personal Data which we have collected from and about you. Subject to certain exemptions, you are entitled to request access to your Personal Data, including for copies of the same, for which we may impose upon you the payment of a prescribed fee.
6.3 If you wish to request for access to your personal data and provision of personal data to be withdrawn, please email to us your written request and withdrawal of consent.
6.4 We reserve the right to charge you an administrative fee for the time spent on processing your written request.
6.5 Further, if required by law, we reserve the right to disclose your personally identifiable data and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on the website or software.
7. RETENTION AND SECURITY OF YOUR PERSONAL DATA
7.1 We hereby advise you and you hereby acknowledge, agree and accept that we require your Personal Data in order to process your online requests and orders to complete your transactions, without which we may not be able to do so. We respect your privacy and take seriously the trust that you place in us, and we therefore follow strict guidelines for protecting and maintaining your Personal Data. We adopt certain procedures to safeguard the Personal Data collected, to maintain data accuracy, to ensure appropriate use of the Personal Data and to prevent unauthorized access or disclosure of the same.
7.2 In general, we shall retain your Personal Data for as long as is required for the purposes for which we collect your Personal Data unless further retention is required under the law. We are continuously committed to ensuring that your Personal Data is stored securely although we wish to remind you that the internet is and has never been a secure environment. Further, communications over the internet such as emails are not secure unless they have been encrypted. As such, we cannot and do not accept any liability or responsibility for any unauthorized access or interception or loss of Personal Data that is beyond our control.
8. YOUR CONSENT TO USAGE OF YOUR PERSONAL DATA
8.1 By you making available, disclosing and sharing to us your Personal Data through the use and subscription of our services online, you irrevocably agree that you give us your express consent to use and process the information for our own benefit and/or disclose such information to third parties.
8.2 If you do not consent to our processing and using your Personal Data, you may exercise your opt-out right by providing written notification to our Personal Data Privacy Officer via email, whose contact details are as provided below. In the absence of your written objections, we are entitled to assume at all times that you confirm your consent and are agreeable to all the terms in this Notice. We do our best to process all requests as promptly as practical, however please note that you may still receive existing communications for a transitional period whilst we update your preferences.
9. LIMITATION OF LIABILITY
9.1 We exercise reasonable efforts to safeguard the security and confidentiality of your information. However, transmissions protected by industry standard technology and administered by humans cannot be guaranteed to be secure.
9.2 By subscribing to our products and services, you irrevocably agree that we will not be liable for unauthorized disclosure of your personal information that occurs through no fault of ours.
9.3 This Notice does not address, and we are not responsible for, the privacy information or other practices of any other third parties, including without limitation any of our affiliates and any third party operating any site to which this website contains a link. The inclusion of a link on the website by no means imply our endorsement of the linked site by us or by our affiliates.
10. COOKIES AND WEBSITE USE
10.1 We may make available through our website (for example, message boards, chat functionality, profile pages and blogs, among other services) to which you are able to post information and materials. Please note that any information you disclose through such services becomes public information, and may be available to visitors to our website and to the general public. We urge you to exercise discretion and caution when deciding to disclose your Personal Data or any other information, on our website.
10.2 By adjusting the settings in your browser while accessing our software services and products online, you can refuse to accept cookies or give yourself the opportunity to accept or reject cookies, or receive notice of cookies. You are also informed that there are available software programs that can block cookies. However, please be informed that refusing cookies may impinge or block altogether your user experience on the website by eliminating personalisation or other features.
11. CONTACT DETAILS
11.1 If you have any questions about this Notice, or have any further queries, or would like to make a complaint or data access or correction request in respect of your Personal Data, you may email us at: firstname.lastname@example.org
12. GOVERNING LAW
12.1 The terms of this Notice and the use, processing and disclosure of your personal data when you subscribe to our products and services on our website are governed by and construed in accordance to the laws of England and Wales.